S. 147 : Reassessment-Survey-Formation of belief of income escaped assessment on wrong facts-Non application of mind-Reason stated non filer-Record shows return was filed on due date-Reassessment notice and consequential order is held to be invalid.[S. 133A, 148]

S.147: Reassessment-After the expiry of four years-Additional ground-No failure to disclose material facts-Deemed dividend-Current transactions-Accumulated profits-Closing credit balance to be verified-Reassessment is bad in law. [S. 2(22)(e), ITAT R. 27]

S. 145 : Method of accounting-Change of method-Advance tax-Interest-Matter remanded. [S. 234A]

S. 145 : Method of accounting-Charge of income-tax-Firm off Chartered Accountants rendering professional Services-service tax-Difference between gross receipts as per Income-Tax Return and service tax cannot be treated as income-Diversion by overriding title-Payments to retired partners and spouses of deceased partners in accordance with clauses of partnership deed-Cannot be assessed as income-Deduction of tax at source-Direction of CIT(A) is held to be proper. [S. 4, 5, 37(1)]

S. 144 : Best judgment assessment-Development of property-Housing project-Work-in-progress-Prescribed Accounting Standards-Addition made on estimated value, without substantial evidence to contradict actual cost recorded is not Justified. [S. 142A, 145(3)]

S.143(3): Assessment-Unexplained investment-Difference between value of closing stock furnished to bank and that shown in books of account-Value in books higher-Higher gross profit offered to tax-No defect pointed out in books of account-No Suppression of profits-Addition is not justified.[S. 69, 145]

S. 143(1) : Assessment-Intimation-Prima facie adjustments-Tax Audit report showing unpaid interest-Prima facie adjustment within jurisdiction-Interest on delayed payment of value added tax-Interest not specified for deduction on actual payment basis-Disallowance is not attracted-Interest liability against delayed discharge of statutory liability is entitled to deduction-Interest-Levy of interest is mandatory. [S. 37(1) 43B(a), 139(1), 234A, 234B, 234C, Maharashtra Value Added Tax Act, 2002 S. 30]

S. 115JB : Company-Book profit-Subsidy in form of excise duty exemption for setting up new industry in Sikkim-Not liable to tax-Excluded from computation of book profits-Reduction of foreign fluctuation translation reserve, inadvertently added while computing book Profits in return to be allowed. [S. 4,115JB(6) Accounting Standard-11.]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Corporate guarantee fees-Arm’s length price of bank guarantee charged at rate of 1 Per Cent. is held to be justified-Optionally convertible loans to subsidiary without charging interest-Entitled to interest at commercial rate which was at Arm’s length-No transfer pricing adjustment on account of interest on loans is warranted-Reimbursement of expenses-Associated enterprises did not incur expenses on behalf of assessee-No adjustment on transaction of reimbursement of expenses.[S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Adjustments for advertisement marketing and promotional expenses-Administrative and business support services-Sales facilitation services-Matter remanded to the AO for verification. [S.92CA, 143(1)(a)]